Chapter 9 Confined

Space Entry

Section 1 Presentation
Section 2 Narrative

1
 29 CFR1910.146
CSE

This is a very important chapter. A lot of people start CSE classes

thinking that they have no confined spaces in their facility. They often
learn that they actually do. Confined spaces are not just pits and tanks;
they can be a pipe chase in your facility, a mezzanine area, or simply a
room without adequate ingress and egress. This standard is often
misunderstood, so be sure you get all you can from the course. If you
find that you have confined spaces then you must have a confined
space program. Confined space programs are usually not simple.

This chapter is not intended to make you a confined space expert or to

train you in confined space entry. It is intended to teach you how to
identify confined spaces and to help you in the application of the
standard.

2
 DANGER
Confined
Space
Do Not Enter
Some people make their confined space programs simple by labeling all
spaces as above and they never let anyone enter them. That is perfectly
acceptable, if you can do it. Doing a confined space program is then
simple because the only procedures required are “Do Not Enter”.
However, if you have very many confined spaces and they have to be
entered for cleaning, maintenance, or other reasons you will find your
written confined space entry program to be one of your larger and more
difficult plans or programs.

3
 29 CFR 1910.146
zConfined Space Entry
zGeneral Industry

ESS

This standard applies to general industry. Other workers generally

have other standards that they comply with.

4
 Define Confined Space
zFirst Determine:
–is it a confined space?
zThen Determine:
–which type of confined
space
ESS

There are three different types of confined spaces depending upon the
hazards within. But whether or not a space is a confined space does not
consider the hazards within. It is based primarily on configuration. We
will first learn to determine whether a space is a confined space or not
and then, if it is a confined space we will learn to determine which
types of confined space it is.

5
 Define Confined Space
zLarge Enough
–can bodily enter
–perform assigned work
zLimited Access & Egress
zNot for Continuous
Occupancy
ESS

In order to be a confined space, the area must have all three of these
elements of the definition of a confined space. Not having all three
doesn’t mean that it’s safe; that just means that this particular
standard does not apply. There is much more to this definition then
initially meets the eye.

6
 Define Confined Space

zLarge Enough
–can bodily enter
–perform assigned work

ESS

If the area is large enough to bodily enter that we must assume that it is
large enough to perform assigned work. But bodily entry does not
necessarily mean you can get your entire body into the space. OSHA
offers no clear definition of exactly what large enough for bodily entry
means, so there is no clear-cut definition. If you have an area that a
person inserts their upper body into then that may be considered large
enough to bodily enter. (If that is the case it doesn’t necessarily mean
it’s a confined space it just means it has this one element of a confined
space). An important point with this example is that the person’s
breathing space is inside the area in question. Another example is when
a person is standing inside something with an open top and part of
their body sticks out the top. Spaces like pits are considered a confined
spaces if they are more than 4 feet deep.

7
 Define Confined Space

zNot Designed for

Continuous
Occupancy
ESS

Not designed for continuous occupancy is pretty clear if you take the
words in the strictest sense. Just because a space has ladders, catwalks,
or controls inside of it does not mean that it is designed for continuous
occupancy. If the architect designed the area to be continually occupied
then the answer is pretty clear. Otherwise if the area does not have
proper lighting or proper HVAC then it is probably not designed for
continuous occupancy. This could easily be a room in your facility.

8
 Define Confined Space

zLimited Access &

Egress

ESS

OSHA doesn’t give us a precise definition of limited access and egress

either. General practice is to take a second look at this element of the
definition if the area does not have proper exits and/or exit ways. If the
area is entered by a ladder then that is definitely limited access and
egress. If it’s entered by stairs that are too steep, that is limited access
and egress. A rule of thumb is if entry and egress does not conform to
NFPA 101 then the area may have limited access and egress. Again,
this doesn’t mean it’s a confined space. It simply means that it has this
element of a confined space.

9
 Define Confined Space
zLarge Enough
–can bodily enter
–perform assigned work
zLimited Access & Egress
zNot for Continuous
Occupancy
ESS

If the area you are surveying has all three of these elements, then it is a
confined space. If you have a confined space you must have a confined
space program.

10
 Define Confined Space

zOnce Defined
– Determine Type

ESS

Once you have determined that a space is a confined space, you must
then determine which type of confined space it is.

11
 Types of Confined Spaces

zPermit Required Space

zAlternate Permit Space
zNon-Permit Space

ESS

These are the three types of confined spaces.

12
 Permit Space
z Hazardous Atmosphere
– potential
z Engulfment Hazard
– potential
z Internal Configuration
– entrapment
– asphyxiation

z Serious Safety or Health Hazard

ESS

A permit-required confined space is a space to which all safety

requirements in the standard apply. This definition is different from the
previous one. With the previous one, you had to have all three elements
of the definition can be a confined space. In the definition of a permit
space, if you have any one of the elements described then the space is a
permit-required confined space.

The word potential clouds this definition. Potential can mean a very
slight chance.

Any confined space that contains a serious safety or health hazard is a

permit-required confined space. This poses a great difficulty. A serious
safety or health hazard is a hazard that could cause death or serious
physical injury. We might not consider 4 inches of water in a confined
space a serious safety or health hazard. But if someone loses
consciousness for some reason, falls, and drowns in the 4 inches of
water, then the water was a serious safety or health hazard. After any
accident causing death or serious injury has already occurred you can
almost always see with hindsight a serious safety or health hazard that
caused the death or serious injury.

For these reasons, many employers designate all confined spaces as

permit-required confined spaces. To do otherwise is to say that no one
will ever be killed or seriously injured in that space. Then if any one is
killed it looks, in hindsight, as if you were wrong. 13
 Alternate Permit Space
zForced Air Ventilation
–control ALL hazards
in the space
zExempt from Most of
Standard ESS

An alternate permit space is one that is exempt from many of the safety
requirements of the standard. It is a space in which forced air
ventilation alone controls all hazards in the space. While forced air
ventilation may control atmospheric hazards, it does nothing for other
hazards. So to designate a space as an alternate permit space you are
again saying that no one will ever be killed or seriously injured in that
space.

14
 Non-Permit Space
zNo Hazard Capable
–causing death
–serious physical harm
zNo Potential Atmospheric
Hazard
–death
–serious physical harm ESS

A non-permit space is defined as one having no hazard capable of

causing death or serious physical harm. A non-permit space is exempt
from most parts of the standard. I would stop short of saying never
designate a space as a non-permit space, but many employers do exactly
that. They feel that to designate a space as a non-permit space is to
certify that no one will ever be killed or seriously injured in the space.

15
 Reclassification
zAlleviationof All Hazards
–duration of entry
zDocumentation
zTemporary Exemption
–reverts to permit space
ESS

There is an alternative to designating a space as a non-permit space

without always having to treat it as a permit-required confined space.
You may designate a space as a permit-required confined space that is
subject to reclassification based upon any number of requirements. You
may say that a certain routine entry of a space can be reclassified to a
non-permit space if, for example, the atmosphere is tested and there
has to be an attendant that stays at the entrance to the space. These
requirements would be any requirements that you decide would render
the space safe to enter without a rescue retrieval system, and the normal
accoutrements that go with a permit required confined space entry.

In this way, you’re not certifying the space will always be safe. You are
provided an opportunity for inspection and preventive measures to be
taken at the time of entry. Reclassification is normally used with simple
spaces and routine entries. In your confined space program, the same
space may require a permit-required entry in nonroutine entries.

16
 Intent of the CSE Standard

z2/3 of Deaths are

Rescuers

ESS

Two thirds of all deaths in confined spaces are rescuers. OSHA realized
that if they can prevent rescuer deaths they would prevent two thirds
of all deaths in confined spaces. They came up with two primary
objectives to accomplish this.

17
 Intent of the CSE Standard

zTwo Primary
Objectives
– Self Rescue
– Non-entry
Rescue
ESS

These two objectives are self rescue and non--entry rescue.

18
 Intent of the CSE Standard

zSelf Rescue
–How?
–Training
Challenge
»acute effects
ESS

Self rescue means providing the means and education necessary for the
entrant to know when to come out of the space before they are injured.

One way this is done is by providing detectors for oxygen content,

flammability, and toxics to the entrants. These detectors normally have
alarms on them that sound win the flammability exceeds 10% of the
LEL, oxygen content drops below 18.5%, or the PEL of the toxics that
are being measured is met. The entrants are also trained to keep an eye
on these detectors and come out of the space if any unacceptable
changes occur.

Another means of providing for self rescue is to train the entrants on

the acute effects of any hazardous atmospheres they may encounter.
With a thorough knowledge of these potential acute effects, the entrant
may recognize that he or she is being affected by a hazardous
atmosphere in time to get themselves out.

Naturally when self rescue works there is no need for rescuer.

19
Intent of the CSE Standard

zNon-entry
Rescue
– Prevent
Rescuer
Deaths
ESS

20
 Intent of the CSE Standard
zNon-entry Rescue
– How?
–Behavioral Effects
–Rescue Retreival
Systems

ESS

Non-entry rescue is the ability to rescue entrants without

actually entering the space.

This is done through the use of a rescue retrieval system that allows the
attendant and/or rescuers to pull the entrant out of the space without
entering themselves. Obviously there are circumstances when
these rescue retrieval systems will not work in this fashion, but when
they do, they protect the rescuer by making it unnecessary to enter.

Another way to accomplish non-entry rescue is by training the

attendant in the behavioral effects of all of the potential hazardous
atmospheres that the entrant might encounter. For example, one effect
of carbon monoxide or oxygen deficiency is confusion. If the attendant
recognizes confusion in the speech or actions of an entrant than they
can instruct the entrant to come out.

21
“Rescue
Retrieval
System”
ESS
-exceptions retrieva.avi

22
 Confined Space Hazards
zHazardous Atmospheres
zTemperature Extremes
zEngulfment
zNoise
zMoisture Hazard
zMechanical Hazards
zConcept of Isolation
ESS

We tend to put the most emphasis on hazardous atmospheres in

confined spaces. But there are many other potential hazards, some of
which are listed above.

The standard mentions the concept of isolation of the space, which is

like a lock out tag out operation only it covers the entire space.

23
 Confined Space Hazards

zAtmospheric Testing
–prior to entry
zAtmospheric Monitoring
–during entry
ESS

You have seen these next few slides before but review them now with
confined spaces in mind.

24
 Atmospheric Testing
1st Oxygen
OSHA Restrictions
2nd Flammability
OSHA Restrictions
3rd Toxics
OSHA Restrictions

ESS

25
 Atmospheric Testing
1st Oxygen
–OSHA Restrictions
2nd Flammability
–OSHA Restrictions
3rd Toxics
–OSHA Restrictions
Stratified Atmospheres
ESS

26
 Atmospheric Testing

“The absence of
evidence is not
evidence of absence”
ESS

27
 Atmospheric Monitoring

zPeriodic vs Continual
zPeriodic Logging
–trends

ESS

28
 Atmospheric Monitoring

Oxygen 21% 20.4% 19.9% 19.7%

Flammable 0 2% 4% 7%
CO 0 0 0 0
H2S 0 0 0 0

ESS

29
 Entry Rescue Services

zPublic vs Private
–If use public at all
»requirements
zResponse Time Required
–1910.151(b) = close proximity
»OSHA definition
ESS

Entry rescue is required when self rescue and non-entry rescue won’t
work. Whether or not you have to provide your own entry rescue has
been widely debated. OSHA issued a letter of explanation that stopped
the debate. It is based upon 1910.151(b), the first aid standard.
According to the first aid standard medical assistance must be available
in close proximity if someone is injured. That includes injuries in a
confined space. OSHA said that medical assistance must be available
within four to six minutes from the time of the injury.

It is not possible for any fire department or rescue squad to meet that
need for you. From the time of the injury, time is passing as the attendant
summons help. More time passes as the call is made to the emergency
dispatcher. More time passes as the dispatcher alerts the proper
responders. More time passes as the responders don protective
equipment and man their truck. More time passes as they drive from
their location to your location and locate the actual confined space
involved. More time passes as they assess the situation and set up the
equipment they will need for their entry. All of this would obviously
take much more than four to six minutes.

It is even unlikely that your own entry rescue team at your facility
could reach the injured party in four to six minutes. But your own in-
house rescue team could certainly make the rescue faster than your fire
department or rescue squad. It is common for facilities to have their
own entry rescue teams that are backed up by public fire department or 30
rescue squad.
 Permit System
zInforms Employees
zMakes Record of Entry
zAdvantage of Space
Specific Permits
ESS

The confined space entry permit serves several purposes. It informs

employees of protective measures to be taken. It makes a record of the
entry including the atmospheric testing and the number of entrants
involved.

Space-specific permits can save lives and avoid accidents. On a space-

specific permit you list the toxics that should be tested for. On a
standard permit, the employees had to determine for themselves what
should be tested for, or at least check the confined space entry plan. On
a space-specific permit, you could list all of the safety equipment needed
for that particular space saving time and providing protection. On a
space-specific permit you could also list the isolation steps, just like
the steps in lock out tag out procedures.

31
 Written Program

zStep-by-step
procedures needed to
make a safe entry

ESS

The written confined space program outlines all of your policies and
procedures for each of your confined spaces. It includes step-by-step
procedures required to make a safe entry into each space.

32
 Confined Space Entry
Introduction

Many workplaces contain spaces that are considered to be "confined" because their
configurations hinder the activities of employees who must enter into, work in or exit from them. In
many instances, employees who work in confined spaces also face increased risk of exposure to
serious physical injury from hazards such as entrapment, engulfment and hazardous atmospheric
conditions. Confinement itself may pose entrapment hazards and work in confined spaces may
keep employees closer to hazards such as machinery components than they would be otherwise.
For example, confinement, limited access and restricted airflow can result in hazardous
conditions that would not normally arise in an open workplace.

The terms "permit-required confined space" and "permit space" refer to spaces that meet OSHA's
definition of a "confined space" and contain health or safety hazards. For this reason, OSHA
requires workers to have a permit to enter these spaces. Throughout this publication, the term
"permit space" will be used to describe a "permit-required confined space."

Definitions

By definition, a confined space:

ƒ Is large enough for an employee to enter fully and perform assigned work;
ƒ Is not designed for continuous occupancy by the employee; and
ƒ Has a limited or restricted means of entry or exit.

These spaces may include underground vaults, tanks, storage bins, pits and diked areas,
vessels, silos and other similar areas.

By definition, a permit-required confined space has one or more of these characteristics:

ƒ Contains or has the potential to contain a hazardous atmosphere;

ƒ Contains a material with the potential to engulf someone who enters the space;
ƒ Has an internal configuration that might cause an entrant to be trapped or asphyxiated by
inwardly converging walls or by a floor that slopes downward and tapers to a smaller
cross section; and/or
ƒ Contains any other recognized serious safety or health hazards.

OSHA's Confined Space Standard

OSHA's standard for confined spaces (29 CFR 1910.146) contains the requirements for practices
and procedures to protect employees in general industry from the hazards of entering permit
spaces.

Employers in general industry must evaluate their workplaces to determine if spaces are permit
spaces. (See flow chart, page 5.) If a workplace contains permit spaces, the employer must
inform exposed employees of their existence, location and the hazards they pose. This can be
done by posting danger signs such as "DANGER -- PERMIT-REQUIRED CONFINED SPACE --
AUTHORIZED ENTRANTS ONLY" or using an equally effective means.

If employees are not to enter and work in permit spaces, employers must take effective measures
to prevent them from entering these spaces. If employees are expected to enter permit spaces,
the employer must develop a written permit space program and make it available to employees or
their representatives.

Alternative to a full permit entry

Under certain conditions described in the standard, the employer may use alternate procedures
for worker entry into a permit space. For example, if an employer can demonstrate with
monitoring and inspection data that the only hazard is an actual or potential hazardous
atmosphere that can be made safe for entry using continuous forced air ventilation, the employer
may be exempted from some requirements, such as permits and attendants. However, even in
these circumstances, the employer must test the internal atmosphere of the space for oxygen
content, flammable gases and vapors, and the potential for toxic air contaminants before any
employee enters it. The employer must also provide continuous ventilation and verify that the
required measurements are performed before entry.
Permit-Required Confined Space Decision Flow Chart
Written Programs

Any employer who allows employee entry into a permit space must develop and implement a
written program for the space. Among other things, the OSHA standard requires the employer's
written program to:

ƒ Implement necessary measures to prevent unauthorized entry;

ƒ Identify and evaluate permit space hazards before allowing employee entry;
ƒ Test atmospheric conditions in the permit space before entry operations and monitor the
space during entry;
ƒ Perform appropriate testing for the following atmospheric hazards in this sequence:
oxygen, combustible gases or vapors, and toxic gases or vapors;
ƒ Establish and implement the means, procedures and practices to eliminate or control
hazards necessary for safe permit space entry operations;
ƒ Identify employee job duties;
ƒ Provide and maintain, at no cost to the employee, personal protective equipment and any
other equipment necessary for safe entry and require employees to use it;
ƒ Ensure that at least one attendant is stationed outside the permit space for the duration
of entry operations;
ƒ Coordinate entry operations when employees of more than one employer are working in
the permit space;
ƒ Implement appropriate procedures for summoning rescue and emergency services, and
preventing unauthorized personnel from attempting rescue;
ƒ Establish, in writing, and implement a system for the preparation, issue, use and
cancellation of entry permits;
ƒ Review established entry operations annually and revise the permit space entry program
as necessary; and
ƒ Implement the procedures that any attendant who is required to monitor multiple spaces
will follow during an emergency in one or more of those spaces.

Controlling Hazards

The employer's written program should establish the means, procedures and practices to
eliminate or control hazards necessary for safe permit space entry operations. These may
include:

ƒ Specifying acceptable entry conditions;

ƒ Isolating the permit space;
ƒ Providing barriers;
ƒ Verifying acceptable entry conditions; and
ƒ Purging, making inert, flushing or ventilating the permit space.

Equipment for safe entry

In addition to personal protective equipment, other equipment that employees may require for
safe entry into a permit space includes:

ƒ Testing, monitoring, ventilating, communications and lighting equipment;

ƒ Barriers and shields;
ƒ Ladders; and
ƒ Retrieval devices.
Detection of hazardous conditions

If hazardous conditions are detected during entry, employees must immediately leave the space.
The employer must evaluate the space to determine the cause of the hazardous atmosphere and
modify the program as necessary.

When entry to permit spaces is prohibited, the employer must take effective measures to prevent
unauthorized entry. Non-permit confined spaces must be evaluated when changes occur in their
use or configuration and, where appropriate, must be reclassified as permit spaces.

A space with no potential to have atmospheric hazards may be classified as a non-permit

confined space only when all hazards are eliminated in accordance with the standard. If entry is
required to eliminate hazards and obtain data, the employer must follow specific procedures in
the standard.

Informing Contract Employees

Employers must inform any contractors whom they hire to enter permit spaces about:

ƒ The permit spaces and permit space entry requirements;

ƒ Any identified hazards;
ƒ The employer's experience with the space, such as knowledge of hazardous conditions;
and
ƒ Precautions or procedures to be followed when in or near permit spaces.

When employees of more than one employer are conducting entry operations, the affected
employers must coordinate entry operations to ensure that affected employees are appropriately
protected from permit space hazards. The employer also must give contractors any other
pertinent information regarding hazards and operations in permit spaces and be debriefed at the
conclusion of entry operations.

Entry Permits

A permit, signed by the entry supervisor, must be posted at all entrances or otherwise made
available to entrants before they enter a permit space. The permit must verify that pre-entry
preparations outlined in the standard have been completed. The duration of entry permits must
not exceed the time required to complete an assignment.

Entry permits must include:

ƒ Name of permit space to be entered, authorized entrant(s), eligible attendants and

individuals authorized to be entry supervisors;
ƒ Test results;
ƒ Tester's initials or signature;
ƒ Name and signature of supervisor who authorizes entry;
ƒ Purpose of entry and known space hazards;
ƒ Measures to be taken to isolate permit spaces and to eliminate or control space hazards;
ƒ Name and telephone numbers of rescue and emergency services and means to be used
to contact them;
ƒ Date and authorized duration of entry;
ƒ Acceptable entry conditions;
ƒ Communication procedures and equipment to maintain contact during entry;
 ƒ Additional permits, such as for hot work, that have been issued authorizing work in the
permit space;
ƒ Special equipment and procedures, including personal protective equipment and alarm
systems; and
ƒ Any other information needed to ensure employee safety.

Cancelled entry permits

The entry supervisor must cancel entry permits when an assignment is completed or when new
conditions exist. New conditions must be noted on the canceled permit and used in revising the
permit space program. The standard requires that the employer keep all canceled entry permits
for at least one year.

Worker Training

Before the initial work assignment begins, the employer must provide proper training for all
workers who are required to work in permit spaces. After the training, employers must ensure that
the employees have acquired the understanding, knowledge and skills necessary to safely
perform their duties. Additional training is required when:

ƒ The job duties change;

ƒ A change occurs in the permit space program or the permit space operation presents any
new hazard; and
ƒ An employee's job performance shows deficiencies. In addition to this training, rescue
team members also require training in CPR and first aid. Employers must certify that this
training has been provided.

After completion of training, the employer must keep a record of employee training and make it
available for inspection by employees and their authorized representatives. The record must
include the employee's name, the trainer's signature or initials and dates of the training.

Assigned Duties

Authorized entrant

Authorized entrants are required to:

ƒ Know space hazards, including information on the means of exposure such as inhalation
or dermal absorption, signs of symptoms and consequences of the exposure;
ƒ Use appropriate personal protective equipment properly;
ƒ Maintain communication with attendants as necessary to enable them to monitor the
entrant's status and alert the entrant to evacuate when necessary;
ƒ Exit from the permit space as soon as possible when:
ƒ Ordered by the authorized person;
ƒ He or she recognizes the warning signs or symptoms of exposure;
ƒ A prohibited condition exists; or
ƒ An automatic alarm is activated.
ƒ Alert the attendant when a prohibited condition exists or when warning signs or
symptoms of exposure exist.

Attendant

The attendant is required to:

 ƒ Remain outside the permit space during entry operations unless relieved by another
authorized attendant;
ƒ Perform non-entry rescues when specified by the employer's rescue procedure;
ƒ Know existing and potential hazards, including information on the mode of exposure,
signs or symptoms, consequences and physiological effects;
ƒ Maintain communication with and keep an accurate account of those workers entering
the permit space;
ƒ Order evacuation of the permit space when:
ƒ A prohibited condition exists;
ƒ A worker shows signs of physiological effects of hazard exposure;
ƒ An emergency outside the confined space exists; and
ƒ The attendant cannot effectively and safely perform required duties.
ƒ Summon rescue and other services during an emergency;
ƒ Ensure that unauthorized people stay away from permit spaces or exit immediately if they
have entered the permit space;
ƒ Inform authorized entrants and the entry supervisor if any unauthorized person enters the
permit space; and
ƒ Perform no other duties that interfere with the attendant's primary duties.

Entry supervisor
Entry supervisors are required to:

ƒ Know space hazards including information on the mode of exposure, signs or symptoms
and consequences;
ƒ Verify emergency plans and specified entry conditions such as permits, tests, procedures
and equipment before allowing entry;
ƒ Terminate entry and cancel permits when entry operations are completed or if a new
condition exists;
ƒ Verify that rescue services are available and that the means for summoning them are
operable;
ƒ Take appropriate measures to remove unauthorized entrants; and
ƒ Ensure that entry operations remain consistent with the entry permit and that acceptable
entry conditions are maintained.

Emergencies

Rescue service personnel

The standard requires employers to ensure that responders are capable of responding to an
emergency in a timely manner. Employers must provide rescue service personnel with personal
protective and rescue equipment, including respirators, and training in how to use it. Rescue
service personnel also must receive the authorized entrants training and be trained to perform
assigned rescue duties.

The standard also requires that all rescuers be trained in first aid and CPR. At a minimum, one
rescue team member must be currently certified in first aid and CPR. Employers must ensure that
practice rescue exercises are performed yearly and that rescue services are provided access to
permit spaces so they can practice rescue operations. Rescuers also must be informed of the
hazards of the permit space.

Harnesses and retrieval lines

Authorized entrants who enter a permit space must wear a chest or full body harness with a
retrieval line attached to the center of their backs near shoulder level or above their heads.
Wristlets may be used if the employer can demonstrate that the use of a chest or full body
harness is not feasible or creates a greater hazard.

Also, the employer must ensure that the other end of the retrieval line is attached to a mechanical
device or a fixed point outside the permit space. A mechanical device must be available to
retrieve someone from vertical type permit spaces more than five feet (1.524 meters) deep.

MSDS

If an injured entrant is exposed to a substance for which a Material Safety Data Sheet (MSDS) or
other similar written information is required to be kept at the worksite, that MSDS or other written
information must be made available to the medical facility personnel treating the exposed entrant.